Joseph Green and Fe Green - Page 2

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                                OPINION OF THE SPECIAL TRIAL JUDGE                                         
                  PANUTHOS, Chief Special Trial Judge:  This matter is before                              
            the Court on respondent's Motion to Dismiss for Lack of                                        
            Jurisdiction.                                                                                  
            The facts pertinent to the disposition of this matter are                                      
            summarized below.                                                                              
             Background                                                                                    
                 Respondent determined deficiencies in petitioners' Federal                               
            income taxes, an addition to tax, and a penalty as follows:                                    
            Addition to Tax           Penalty                                                              
            Year       Deficiency          Sec. 6661           Sec. 6662(a)                                
            1988       $11,846.82          $2,961.71              ---                                      
            1990        10,076.82             ---              $2,015.36                                   
                  Duplicate notices of deficiency dated July 8, 1994, were                                 
            sent to Fe Green (petitioner) and Joseph Green at 1503 Hastings                                
            Mill Road, Pittsburgh, Pennsylvania, and to P.O. Box 1136, Cherry                              
            Hill, New Jersey.  United States Postal Service Form 3877 (Form                                
            3877) reflects that the notices of deficiency were mailed on July                              
            8, 1994.  On June 24, 1993, approximately one year prior to the                                
            mailing of the notices of deficiency, petitioner notified the                                  
            Internal Revenue Service Appeals Office in Newark, New Jersey                                  
            (Appeals), by letter, of Joseph Green's new address in Lyndhurst,                              
            New Jersey.  No notice of deficiency was sent to Joseph Green's                                
            Lyndhurst, New Jersey, address.                                                                
                  Petitioners filed a petition seeking a redetermination of                                
            their tax liability for 1988 and 1990.  At the time of filing the                              
            petition herein, petitioner resided in Pittsburgh, Pennsylvania,                               




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